Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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Provisional attachment of immovable property was sustained where the property was acquired during the disclosed offence period and found to be directly derived from narcotics-related proceeds of crime. The absence of documentary proof of lawful income, unexplained banking transactions, and admissions concerning use of narcotics-sale proceeds supported the required nexus with the scheduled offence. Statements made under Section 50 of the Prevention of Money Laundering Act were treated as constitutionally valid and reliable where recorded under summons, written by the individuals concerned, and corroborated by investigative material. The allegation of duress was rejected, and the appeal challenging the attachment was dismissed.
Provisional attachment of immovable property was sustained where the property was acquired during the disclosed offence period and found to be directly derived from narcotics-related proceeds of crime. The absence of documentary proof of lawful income, unexplained banking transactions, and admissions concerning use of narcotics-sale proceeds supported the required nexus with the scheduled offence. Statements made under Section 50 of the Prevention of Money Laundering Act were treated as constitutionally valid and reliable where recorded under summons, written by the individuals concerned, and corroborated by investigative material. The allegation of duress was rejected, and the appeal challenging the attachment was dismissed.
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